4. Our lawful bases for the collection and use of your data

We process data you provide us lawfully, fairly, and transparently. Under the GDPR-EU, our legal bases include Contract obligations, compliance with Legal Obligations, Vital interests as well as your Consent and/or our Legitimate Interests, provided these are not overridden by your rights.

Our lawful bases for collecting or using personal information to provide psychological and psychotherapeutic care, supervision, educational services, and other products are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability. You right to consent might not be apply when data processing is necessary to protect the vital interests of the client or others such as: Serious Risk of Harm, Legal Obligation/Public Interest or Inability to Give Consent.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests - we’re collecting or using your information because it benefits you and our service ensuring accountable, safe, effective and ethical practice, without causing an undue risk of harm to anyone.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

• Legal Requirements (Legal Obligation): To document decisions as  necessary for compliance with a legal obligations related to psychological practice and comply with applicable laws, court orders, or regulatory requirements

Our lawful bases for collecting or using personal information for client portal functionality are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

• Legal obligation – we have to collect or use your information so we can comply with applicable law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for Communications and marketing:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All other data protection rights may apply, except the right to erasure, the right to object, and the right to data portability. Our legitimate interests are

  To communicate with existing/new clients and subscribers about new features and service updates, security notices, invoices, and responding to inquiries. To inform about newly developed services or material, special offers/ promotional opportunities to help maximize value.

You may opt out of non-essential emails (e.g. news/ practice communications) at any time using the opt-out link provided or by emailing us. You cannot opt out of essential communications like therapy updates or billing notices while your therapy contract is active.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using anonymised personal information Service evaluation, statistical analysis and publication purposes are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All other data protection rights may apply, except the right to erasure, the right to object, and the right to data portability. Our legitimate interests are:

Analysis and improvement of service effectiveness and research. This data information is converted into anonymised and non-identifiable numerical data, and aggregated with other data for group-level analysis. You may withdraw your consent up until the data has been incorporated into the compiled dataset by contacting us using the information provided above. After this point, withdrawal of data is not possible as it is de-identified and cannot be linked back to any individual. In case of publication all data is fully anonymised and non-identifiable and cannot be linked back to any individual.